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Data Treatment Policy

In compliance with Law 1581 of 2012, Decree 1377 of 2013 and all other norms of the Republic of Colombia that modify, add to, compliment or develop said Law and Decree, AJOVER S.A.S, a Company constituted under Colombian Law (“AJOVER”), hereby communicates its Data Treatment Policy, which describes, amongst others, the reach and objective of the treatment that AJOVER will give to your personal data, as well as the procedures and mechanisms by which AJOVER will guarantee that your rights as owner of your personal data can be made effective.

AJOVER guarantees that your privacy will be fully protected; you can be certain that the information which you give us will only be used in accordance with this Data Treatment Policy, thereby complying with existing legislation of the Republic of Colombia.At the same time, in order to prevent any unauthorized access or dissemination, we have put in place various physical, electronic and administrative procedures to safeguard and insure all the information that we collect.

Definitions.Habeas Data Rights: Set of rights that enable you as owner of your data to verify that the information you give us is collected and treated according to the dispositions set forth in the law and according to the purpose communicated by us and for which you submitted your personal data to us.

These rights allow you to, amongst others, consult, update and request that your data be eliminated from our data base. The latter right exists if by the time you submit your request there is no contractual or legal obligation to keep your data in our files.

Authorization: Your explicit consent for AJOVER to manage and treat your data, according to the intent described in the Data Treatment Policy and in the authorization that you will be asked to provide or not.

Data Owner: This is you, once you give us the authorization to treat your Data.

Treatment: Any operation or set of operations that we undertake using your data, such as collection, storage, usage, circulation or elimination.

Data Base: Organized set of personal data which is subjected to treatment.

Personal Data: Any information that individually or collectively can identify you.

Data is classified as public, private, semi-private or sensitive.

Public Personal Data: Refers to data of general interest, such as what is contained in public documents, public records, gazettes, official bulletins and judicial sentencing documents that are not subject to any sort of reserve. It can be data such as your name, identification number, civil status, profession or job.

Private Personal Data: This refers to data that concerns only you as owner, it is intimate and reserved in nature. Your private data includes home address and telephone number, information extracted from a home inspection report, your health and your sexual orientation.

Semi-Private Personal Data: This encompasses your private data which under certain circumstances can be of interest to a certain group of people, e.g. your credit score.

Sensitive Personal Data: Information that affects your intimacy and the inappropriate use of which can lead to discrimination, such as race or ethnic origin, political affiliation, religious or philosophical convictions, membership in unions, social organizations or human rights organizations or those that promote the interests of any political party or that guarantee the rights of political opposition, as well as information concerning your health, sexual life and biometric data (fingerprints, pictures, DNA, amongst others).

Special Data: Refers to the treatment of data concerning minors and sensitive data.

Data Manager: Person or entity that decides over the collection of data and its treatment. AJOVER is responsible for a large amount of data that is stored in its data bases on its customers, employees and suppliers.

Data Handler: Person that undertakes the treatment of the data on behalf of the Data Manager.

Data Transmission: Treatment of personal data that implies its communication within (national transmission) or outside Colombia (international transmission) and the purpose of which is for the Data Handler to treat said data on behalf of the Data Manager.

Data Transfer: Sending of personal data by the Data Manager or the Handler from Colombia to another Data Manager within or outside the country (national or international transfer respectively).

Scope and reach of data managementIn order to fulfill its corporate purpose and develop its commercial activities, AJOVER adopts this Data Treatment Policy which explains how the Company will treat the personal data that it collects. The policy specifically addresses the parameters under which AJOVER obtains, collects, utilizes, stores, guards, circulates, transfers and suppresses the personal data that it has access to through any means, having obtained previous specific and informed authorization, other than in exceptional cases established in the law.

The treatment that AJOVER gives to the personal data as the responsible party is limited to the purposes stated below and especially those that are expressly stated in the authorization format which will be made available to you for your review and acceptance. At the same time AJOVER will make every effort to ensure that the treatment given by any responsible or third party to your personal information abides by the guidelines established in this Data Treatment Policy. The objectives of the data treatment are:

• Manage all information required to develop our business and commercial activities.

• Validate the data provided by current or potential customers and suppliers, include them in the data base, offer products and services, monitor and ensure the quality of the goods and services provided.

• For documentary support and insurance purposes, AJOVER will sub-contract third parties and grant them access to personal data, which does not exonerate AJOVER from its responsibility nor its obligation to maintain said information private and confidential.

• Share this information with its commercial partners to allow customers to choose amongst the products and services offered by said partners; this includes sending the pertinent commercial information to customers.

• Verify that the data treatment performed by our employees as Data Managers and Handlers is in accordance with our Data Treatment Policy.

• Study and measure worker’s satisfaction.

According to the purposes described, the types of data treatment which AJOVER performs are as follows:

• Collect, store and process all information provided by data owners in one or more data bases, in the format which it deems appropriate.

• Verify, corroborate, prove, validate, investigate or compare the information supplied by the data owners with any other information that has been obtained in a legitimate manner.

• Access, consult, compare and evaluate any and all information that is stored in the data bases of any credit or financial risk rating agency and/or any legitimately established security/legal clearance agency, whether private, state owned, local or foreign.

• In case AJOVER is not in a position to treat the data through its own means, it may transfer said data to a third party who will guarantee adequate conditions of confidentiality and security of the data transferred for treatment.

Sensitive data

AJOVER endeavors to not treat sensitive data. Nevertheless, if in the course of business we were to ever need to treat data that falls under this category, then this treatment will abide by the procedures established in the law for said purposes, including the confidentiality and right to intimacy that are legally required.

You as the data owner are not required to provide any data of this sort. However, you understand that there are certain processes and procedures that require the treatment of this type of data.

Exchange, transfer and transmission of information

AJOVER may provide any information and personal data that it collects, to its subsidiaries, agencies, affiliates, or to companies and individuals in Colombia or abroad, even in countries that do not present adequate data protection levels, so long as AJOVER believes that the data processed will improve how those companies and/or individuals are serviced.

Information security

AJOVER has implemented procedures that guarantee the safety, transparency and correct use of information, which can be verified at any time by the data owners.

Rights of data owners

You as data owner have the right to know, update, rectify and eliminate your personal data, through the procedures established in Law 1581 of the Republic of Colombia.

AJOVER is responsible for the storage and treatment of personal data.

In case you as data owner have any doubts, questions or complaints with respect to the treatment of personal information, please write to us at habeasdata@ajover.com, keeping in mind the following procedures:

Procedures

Consults

Data owners may consult any of their personal information which is stored in any of the company’s data bases. AJOVER will provide you with all information contained in your individual registry and any information related to your form of identification. Please keep in mind:

2. In addition you must include a copy of your ID, and if you are not acting as data owner, kindly indicate in what capacity you are placing this inquiry and attach a copy of the document that enables you to place said inquiry. If you are acting as an attorney-in-fact, please include a copy of the power of attorney, duly executed.

In you are acting on behalf of an interested third party, please include a copy of the document which grants you this right.

3. AJOVER will have 10 working days to respond to your inquiry. If the company cannot respond within that timeframe, we will inform you of the reasons for the delay and let you know when we will respond, which in no case may be more than 5 working days after the expiration of the first 10-day term.

Complaint

The data owner who believes that information contained in our data base must be corrected, updated or suppressed may file a complaint to AJOVER. Please keep in mind that:

2. In addition you must include a copy of your ID, and if you are not acting as data owner, kindly indicate in what capacity you are placing this complaint and attach a copy of the document that enables you to place said complaint. If you are acting as an attorney-in-fact, please include a copy of the power of attorney, duly executed.

In you are acting on behalf of an interested third party, please include a copy of the document which grants you this right.

3. AJOVER will have 15 working days to respond to your complaint. If the company cannot respond within that timeframe, we will inform you of the reasons for the delay and let you know when we will respond, which in no case may be more than 8 working days after the expiration of the first 15-day term.

4. If the complaint filed has incomplete information, we will ask for the missing information within 5 days after receiving it. If after two (2) months from the date of the original complaint the data owner has not completed the information, we will understand that the complaint has been dropped.

5. Once we receive the complete complaint and at the latest two (2) business days after that, we will include a note in our data base that reads “complaint in process” and the reason for the complaint. This note will be kept until we give a definitive answer to the complaint.

This Data Treatment Policy is valid from October 2016. AJOVER’s data bases are kept for the duration needed for it to fulfil its business purpose, its legal mandate and in compliance with any legal data retention requirements.

Contact information

For purposes of this Policy all data owners may contact AJOVER directly, either by email to habeasdata@ajover.com or through written communication sent to AJOVER S.A.S, Calle 65 Bis No. 91 – 82, Bogota, Colombia.